Almost every tax firm says it handles appeals. Far fewer are built for the faceless CIT(A) and the Tribunal. Here is what genuine specialisation looks like, how to verify it, and where DSRV India fits.
Nearly every chartered accountancy firm in India will tell you it handles income tax appeals. The claim is usually true and almost never useful, because appeal work sits on a spectrum.
At one end, a firm that files the appeal form and repeats the submissions already made to the Assessing Officer. At the other, a firm that drafts grounds designed to be read by the Tribunal, appears regularly before a specific bench, and knows which arguments that bench has accepted before.
Both are "handling appeals." Only one is specialisation.
Since you cannot tell them apart from a website, this page sets out the checks that actually work.
Three structural changes landed within months of each other, and how a firm talks about them tells you a great deal.
The forms and sections all moved. From 1 April 2026, the first appeal is filed in Form 99 under Rule 167, not Form 35. The ITAT appeal is Form 115 under Section 362, not Form 36. Cross-objections are Form 116. The appeal chapter sits in Sections 356 to 374 of the Income-tax Act, 2025. Our guide on filing a first appeal to the CIT(A) with Form 99 sets out the full mapping.
If a firm is still describing Form 35 as current, that is a live signal about how closely they follow the area.
ITAT filing is now digital by default. Since 3 January 2026, an ITAT appeal is instituted electronically with a Digital Signature Certificate. Paper filing no longer completes the act. A firm that has not filed since the change will discover this at the deadline.
The ITAT deadline is no longer 60 days. It is two months from the end of the month in which the order is communicated. An order received on 3 September and one received on 28 September share the same deadline. Firms that still quote 60 days are working from memory.
1. They lead with limitation, not merits. A specialist asks which assessment year, when the order was served, and whether tax on returned income has been paid, before discussing whether the addition is right. Those three answers determine whether an appeal is even admissible.
2. They draft grounds as though the Tribunal will read them. Grounds of appeal cannot be changed later without leave. A specialist writes them issue by issue, tied to specific figures and annexures, because the same document has to work at the CIT(A) and again two years later.
3. They know the appeal is decided on paper. First appeals run through the faceless system. There is no hearing and no appearance. That rewards indexed submissions and a clear document map over oral advocacy, and firms built around the hearing room adapt badly.
4. They file the stay application alongside the appeal. Filing an appeal does not stop recovery. A firm that does not raise this unprompted is solving half your problem. Our guide on how to get a stay of demand under Section 220(6) covers why the 20 per cent figure is not a legal requirement.
5. They can name benches and outcomes. Ask which ITAT benches they appear before and how often. Specialists answer with specifics. Generalists answer with adjectives.
6. They price the whole path, not the next filing. Realistic timelines run 18 months to four years to a Tribunal order, plus time for the Assessing Officer to give effect to it. A firm that cannot walk you through that arithmetic has not run many. Our note on how long an ITAT appeal really takes and what it costs sets out the stages.
7. They tell you when not to appeal. Rectification, revision before the Commissioner within one year, or simply paying a small correct demand are all sometimes the better answer. A firm that has never recommended one of those will not recommend it to you.
Four checks, all independent of anything the firm tells you.
The second check is the most revealing and the least used. A firm that only ever cites helpful authority in its own writing will do exactly the same in your grounds of appeal, and the appellate authority will notice.
A chartered accountant can appear before the CIT(A), the JCIT(A) and the ITAT. A chartered accountant cannot appear in the High Court or the Supreme Court.
So when you ask a firm about specialisation, ask what happens if the matter goes further. The right answer is that they prepare the record and brief counsel, and that they will tell you when the matter has reached that point. A firm that is vague about where its own right of audience ends is a firm that will be vague later.
Defaulting to the compliance firm. The people who file your returns are answering for their own filings. That makes objectivity hard, and it is a different skill in any case.
Appointing near the deadline. Thirty days for the first appeal, and two months from month-end for the Tribunal. A firm engaged in the final week files what is achievable, not what is right.
Buying the cheapest quote on a large demand. The filing fee is capped at ₹10,000 at the Tribunal regardless of the amount in dispute. On a substantial demand, the professional fee is not where you should be economising.
We handle income tax appeals as a core part of our practice rather than an adjunct to compliance: drafting grounds and statements of facts built for faceless scrutiny, filing Form 99 and Form 115, running stay applications in parallel, and appearing before the CIT(A), the DRP and the ITAT. Where a matter reaches the High Court, we prepare the record and work alongside counsel.
DSRV and Co LLP has been in practice since 1987 and is a peer reviewed LLP registered with ICAI, FRN 006993N/N500073. Our published work on appeals, reassessment, transfer pricing disputes and tax litigation generally is on this site. Read it and judge the thinking, which is a better test than any claim we could make.
We are probably not the right fit if you want the cheapest possible filing, if you need a physical presence across a dozen states, or if you want to be told your position is safe.
Ask which limitation date applies, which benches they appear before, who drafts and who attends, whether a stay application is needed, and when they would advise against appealing.
No. From 1 April 2026 the first appeal is filed in Form 99 under Rule 167 of the Income-tax Rules, 2026.
Yes. A CA is a recognised authorised representative and appears before the Tribunal regularly. Only an advocate can appear in the High Court.
Not necessarily. What matters is experience before the bench with jurisdiction over your case, since matters are heard where the assessment sits.
Realistically 18 months to four years from filing to a Tribunal order, with more time for the Assessing Officer to give effect to it. Benches and complexity vary widely.
Usually yes. The Tribunal appeal is argued on the record the first appeal created, and handovers lose grounds.
Send us the order and the demand notice. We will confirm the deadline, tell you honestly whether the appeal is worth running, set out what it will cost across the full path, and file the stay application alongside so recovery does not start while you wait. Book a free 15-minute appeal assessment with DSRV and Co LLP, as part of our income tax litigation practice.
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